01908 889 764

Privacy policy

Nomad AI (trading as Kulea.ma)

Company No. 09350222

This Privacy Policy illustrates the manner in which Nomad AI Ltd (trading as Kulea.ma) collects, maintains and discloses Personal Data collected from users (you) of Nomad AI’s websites (Site). This Privacy Policy applies to this site, all other social media pages of Nomad AI located at https://www.facebook.com/kulea.ma, https://twitter.com/Kulea_ma, https://www.linkedin.com/feed/, https://kulea.freshdesk.com/support/solutions and other services provided by us offline and online.

This Privacy Policy only extends to practices carried out by Nomad AI and does not apply to Personal Data and information processed on behalf of our subscribers which is received through Nomad AI’s marketing automation software used by our subscribers. Information uploaded via the marketing automation software is governed by the terms of use of the subscriber’s agreement as opposed to this Privacy Policy.

Who we are

Nomad AI Limited, trading as (Kulea.ma) company registration number: 09350222

Information Commissioners Office registration number: ZA460736

GDPR

As a data controller and a data processor Nomad AI must comply with the GDPR. GDPR refers to the General Data Protection Regulations which came into effect on 25th May 2018.

Data processor: Responsible for processing Personal Data on behalf of a controller.

Data controller: Determines the purposes and means of processing Personal Data.

We value your privacy and we are committed to:

  • Not selling your information.
  • Keeping your data safe, secure and confidential.
  • Using your information lawfully and in accordance with GDPR.
  1. What information does Nomad AI collect?

Personal Data is defined in Article 4 GDPR as information relating to an identified or identifiable natural person. An identifiable person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (IP address) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

We collect Personal Data and any other information which does not fall within that definition above i.e. which cannot be used to reveal a user’s identity. This information may include the browser name, the type of computer and technical information about the users means of connection to our site, such as operating system and the internet service providers utilized. We use this information for product and service improvement.

  1. Sensitive Information

We collect information about your browsing habits on https://kulea.ma and other associated websites discussed in the first paragraph of these policies and through the Kulea.ma web application therefore we ask that you do not send us or disclose to us any sensitive Personal Data (e.g., racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purposes of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation), unless you consent to us processing that data.

  1. Web Browser Cookies

We use Cookies to distinguish you from other users of our website in order to help us improve your experience of our website and our services. Where used, these cookies are downloaded on your computer and stored on the computer’s hard drive. However, this information may identify you personally.

When you use our website, you can refuse cookies or alternatively you can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting on your computer.

For further information about the cookies we use see Nomad AI’s cookie policy at https://kulea.ma/cookies/

  1. How do we collect your Information?

Nomad AI collects Personal Data and other information in several ways, for instance:

  • Cookies: Our Site uses cookies to enhance user experience. A user’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. Users may set their web browsers to refuse cookies or to alert them when cookies are being sent, Nomad AI will not collect cookie data where the data subject does not give their free and specific consent.
  • Through our website: Nomad AI collects information through our websites when you complete a form.
  • Offline: Nomad AI collects information from you offline during phone calls with our sales representatives and when we attend events i.e. networking events.
  • User Consent: Nomad AI collects information such as user location and address when you voluntarily provide it to us.
  • Miscellaneous Information: Nomad AI obtains information about you from other sources, such as public databases, joint marketing partners and social media platforms, as well as GDPR compliant third parties.
  • When they use Kulea.ma web applications: When you use or download the Kulea.ma web application we track and collect application usage data; for example, what information or files were downloaded and at what date and time the download took place.
  • Anonymising and Aggregating Personal Data: Nomad AI will start processing anonymised and consolidated controller’s data via a self-optimising marketing automation program (SOMA) aiming to increase the quality of the controllers marketing communications. This system will increase the controller’s marketing reach by creating behavioural patterns of individuals other than the current data subjects. This information is not Personal Data as it does not fall within the definition of Article 4 GDPR, because it does not identify the user of the website.
  1. How do we use your personal information?

Nomad AI may collect and use user’s personal information for the following purposes:

  • Improving and personalising user’s digital experience.
  • To send periodical marketing communications including emails which may interest you, in compliance with GDPR.
  • To send you information regarding changes to our websites and any changes to our terms and conditions, privacy policies and cookie policies.
  • If a user decides to opt-in to our email alerts, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the user would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email. ​
  • To comply with applicable laws and regulations and for other business purposes, such as internal audits and accounting.
  1. Legal basis

Article 6 of GDPR sets out the six legal grounds for processing Personal Data.

Processing persona data shall be lawful only if one of the following grounds applies:

  • Processing is necessary for the performance of a contract with the data subject.
  • Processing is necessary for compliance with a legal obligation.
  • Processing is necessary to protect the vital interests of a data subject.
  • Processing is necessary to perform a task is carried out in the public interest.
  • Legitimate Interest.

Nomad AI’s legal basis for processing Personal Data will vary upon the circumstances in which the Personal Data was collected. In some circumstances, we rely on your consent as our legal basis for processing your Personal Data and, we will also process your information when it is necessary to do so in order to enter into a contract with you or in order to perform a contract with you. We also collect and process Personal Data when it is in our legitimate business interest to do so, such as direct marketing for promoting our services and products to other businesses.

  1. Retention of Personal Information

We will retain your Personal Data for a period of time consistent with the original purpose of collection discussed in s.5 of these privacy policies. Once the information is no longer necessary to fulfil the specified purpose we will endeavour to promptly delete it.

  1. Profiling and Automated Decision Making

Profiling and Automated Decision Making: Nomad AI carries out automated and quasi-automated data processing activities in order to establish what services might be of interest to our clients and when they may be ready to purchase the product. Nomad AI does not use automated decision-making technologies in circumstances which would result in legal effects to data subjects.

Why does Nomad AI use this technology? Nomad AI uses cookie tracking technology to identify key products, topics and services that may be of interest to our customers in order to serve them with relevant, timely and personalised digital communications. 

  1. How do we protect your Personal Data?

We have implemented appropriate organisational, technical and administrative measures to protect Personal Data stored by Nomad AI, including security controls to protect against alteration, disclosure and destruction of your Personal Data and to prevent any unauthorised access to our systems. If you have any questions regarding our security of processing please contact us via our website portal or at gdpr@kulea.ma.

  1. Sharing your personal information

We do not sell, trade, or rent users’ personal identification information to others. We will not allow unrelated third parties and companies to use your personal information for any purpose without your consent.

We may share your information with;

  • Business Partners and trusted affiliates: Nomad AI may disclose Personal Data and other information with our business partners and trusted affiliated for the purposes outlined in this privacy policy.
  • Sub-processors (Service Providers): We engage various companies to perform tasks on our behalf such as web hosting and developers, operating our mailing services. When we share your information to our service providers, we require our service providers to maintain a level of privacy, confidentiality and security in accordance with the relevant laws and regulations.
  • With third-party search engines that may index user profile pages and usernames as part of the URL of the user profile page by default.
  • Business transfers: We may disclose Personal Data to third parties in the event of sale, merger and acquisition, corporate restructuring or disposition of any portion of our company.
  • Disclosure to law enforcement agencies: We may release Personal Data to public and government authorities when we reasonably believe that disclosure is necessary, to protect our rights, for tax enforcement, to investigate fraud and for national security purposes.

When third parties are given access to our Personal Data, Nomad AI will take appropriate contractual, technical and organisational measures designed to ensure that Personal Data is processed only to the extent that such processing is necessary, consistent with this Privacy Policy, and in accordance with applicable law.

  1. International transfers of Information

Nomad AI will only make international data transfers to the United States when it is necessary to do so in order to fulfil a contractual obligation between the data subject and the controller. All international data transfers are made to trusted service providers which are under a contractual obligation not to misuse your data. Any of your data which is transferred to the US will be protected under the EU-US Privacy Shield.

EU-US Privacy Shield

The EU-US privacy shield framework protects fundamental rights of anyone in the EU whose Personal Data is transferred to the United States for commercial purposes.

Nomad AI  is in the process of repatriating all data to the EU.

  1. Information regarding children

This website is not intended for minors under the age of 18. Nomad AI does not knowingly or intentionally collect information about minors under the age of 18. If you believe that we have mistakenly collected such information, please contact us at gdpr@kulea.ma so we can erase the information from our systems.

  1. Your rights under GDPR

Articles 13 to 22 of GDPR define your data protection rights under EU law.

Your rights are the following:

  • The right to be informed.
  • The right of access (subject access request).
  • The right to rectification.
  • The right to erasure (right to be forgotten)
  • The right to restrict processing.
  • The right to data portability.
  • The right to object.
  • Rights on profiling and automated decision-making.

Nomad AI is eager to protect your rights under GDPR, therefore If you have any queries or concerns regarding your rights please do not hesitate to contact us at gdpr@kulea.ma or alternatively call us at 01908 889764.

In the unlikely event that you do not receive a response within 30 days you have the right to contact the Information Commissioners. Officer Wycliffe House, Water Lane, Wilmslow, SK9 5AF, Email: https://ico.org.uk/global/contact-us/email or telephone: 0303 123 1113.

  1. Changes to this Privacy Policy

We may update this Privacy Policy at any time. When we do, we will revise the updated date at the top of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications.

  1. Your Acceptance of these terms

By using this Site, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Site. Your continued use of the Site following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes. You acknowledge that this website may contain links to other sites. Please be aware that Nomad AI has no control or influence over the privacy practices of such other sites

  1. Breach Notification

In the unlikely event of a data breach we will notify our subscribers, customers and the Information Commissioners Office without undue delay, and in any event within 72 hours after becoming aware of a Personal Data breach.

What is a Personal Data breach? For the purposes of GDPR a Personal Data breach is the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data.

  1. Contacting us

Your privacy is important to us. If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Site, please contact our Data Protection Officer at gdpr@kulea.ma or at

AU39 Science and Innovation Centre,
Bletchley Park, Milton Keynes
MK3 6EB